Although there are many detailed comments, they stratify into 5 general categories

*Because of the maturity of standards and EHR technology, the Stage 3 goal should be menu set rather than core*Because of the maturity of workflows, the Stage 3 goal should be a certification requirement (the technology can do it) but not a meaningful use requirement*Standards do not exist and it is premature to include the goal in Stage 3*Workflow/experience with production system implementation does not exist and it is premature to include the goal in Stage 3*We agree with the Policy Committee goal as worded

In general, the Standards Committee applauds the aspirational nature of many of the goals. They seem like a reasonable direction. The challenge is timing. 18 month cycles to design, implement and adopt product require that mature standards exist and pilot workflows have proven efficacy.

I described the caveats raised by the Standards Committee when goals seemed too aspirational for Stage 3. For example :

*No standards or technologies exist to represent knowledge/rules and enable their automated incorporation into EHR workflows. *There is no way to electronically broadcast computable guidelines for immunization administration for children into EHR workflows.*At present there are no standards for contraindications to immunizations*The is no standard way to electronically broadcast computable guidelines for drug/drug interactions into EHR workflows.*There is no way to broadcast rules that would create "smart problem lists" such as declaring everyone with a hemoglobin A1c greater than 9 to be a diabetic.*Incorporating patient generated data into EHRs requires new patient friendly vocabularies and code sets that will map into EHR data structures and protect data integrity.

We agree with many of the goals and believe that progress with Meaningful Use Stage 2 should be extended with higher thresholds which enable organizations and professionals to consolidate our gains.

I am confident that the smart people at ONC will incorporate testimony from stakeholders, the deliberations of the policy committee, and the feedback from the standards committee into a set of go forward recommendations for Meaningful Use stage 3.

Given that the country is in the midst of ICD-10, Accountable Care/Healthcare Reform implementation, value-based purchasing, Meaningful Use stage 2, and HIPAA revisions, many clinicians, vendors, and IT professionals are feeling overwhelmed. If Meaningful Use Stage 3 follows existing timelines and focuses on a few key domains, raising the thresholds on existing criteria and incorporating more interoperability where standards are mature, we'll achieve a balance of benefit and burden.